Privacy Policy

1. About this policy

This Privacy Policy explains how [LEGAL ENTITY NAME] ABN [PLACEHOLDER] (“Anaestra”, “we”, “us”, “our”) collects, holds, uses, and discloses personal information in connection with the Anaestra pre-operative assessment service.

We are bound by the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs). As a health service provider and technology platform handling patient health information, we take our privacy obligations seriously.

By using Anaestra or submitting information through our service, you agree to the collection and use of information as described in this policy.

2. Who this policy applies to

This policy applies to two groups of people:

• Subscribing practitioners — registered anaesthetists and their practice staff who use the Anaestra service
• Patients — individuals whose pre-operative assessment information is recorded in Anaestra by their treating anaesthetist

Note for patients: The anaesthetist responsible for your care is the primary handler of your health information. Anaestra processes that information on their behalf and under their direction. For questions about how your specific health information is used, contact your treating anaesthetist directly.

3. Information we collect

3.1 Subscriber (practitioner) information

When a practitioner subscribes to Anaestra, we collect:

• Full name and professional title
• Email address (used for login and service communications)
• FIDO2/WebAuthn credential data (biometric unlock — stored as a cryptographic key, not biometric data itself)
• Billing information (processed by our payment provider — we do not store card numbers)
• IP addresses and access timestamps (in security audit logs)

3.2 Patient health information

Patient health information is entered into Anaestra by the treating anaesthetist or collected via the patient pre-operative questionnaire. This information is sensitive information under APP 3 and is afforded the highest level of protection.

Patient information may include:

• Name, date of birth, and contact details
• Medical history, current medications, and allergies
• Pre-operative assessment findings and clinical notes
• Annotated clinical diagrams and digital signatures
• Hospital or facility patient identifiers (URNs)

4. How we use your information

4.1 Subscriber information

• Providing and managing access to the Anaestra service
• Sending login codes and service communications
• Billing and account administration
• Security monitoring and incident response
• Improving the service (using aggregated, de-identified analytics only)

4.2 Patient health information

Patient health information is processed solely on the instructions of the treating anaesthetist. We do not use patient health information for any purpose other than delivering the service. Specifically:

• We do not use patient health information for our own commercial purposes
• We do not sell patient information
• We do not use patient information to train machine learning or AI models
• We do not share patient information with third parties except as described in Section 6

5. How we store and protect your information

All patient health information is stored in Australia in encrypted form. We implement the following security measures:

• Encryption at rest: Patient identifying information (name, date of birth, phone number) is encrypted using AES-256 at the database column level. Annotations and signatures are AES-256 encrypted in file storage.
• Encryption in transit: All connections use TLS 1.2 or higher. HSTS is enforced.
• Access control: Each practitioner can only access their own patients. Row-level security is enforced at the database layer.
• Authentication: Multi-factor authentication (email OTP + biometric Face ID). No passwords stored.
• Audit logging: All patient record access is logged with timestamp and IP address.
• Penetration testing: The application undergoes independent security testing by CREST-accredited testers prior to regulated facility onboarding.

Data is hosted on Supabase infrastructure located in the AWS ap-southeast-2 (Sydney) region. No patient data is stored outside Australia.

6. Disclosure to third parties

We use a small number of trusted third-party service providers to operate the Anaestra platform. All sub-processors are contractually bound to handle information consistently with this policy and the Australian Privacy Principles.

We do not sell personal information to any third party. We do not share information with advertisers or data brokers.

Overseas disclosure (APP 8)

Resend (United States) processes practitioner email addresses to deliver login codes. Sentry (EU) receives anonymised error reports with no patient data. We have taken reasonable steps under APP 8 to ensure these providers handle personal information consistently with the Australian Privacy Principles.

7. Data retention

We retain subscriber account information for the duration of the subscription and for 30 days following cancellation to allow data export.

Patient health information is retained on behalf of the treating practitioner for the duration of the subscription. On cancellation:

• Data is available for export for 30 days post-cancellation
• After 30 days, production data is permanently deleted
• Backup copies are purged within 90 days

Note for practitioners: Health record retention obligations (minimum 7 years for adults under most Australian state legislation) rest with you as the health service provider. You are responsible for exporting records before cancellation if required for your retention obligations.

See our full data retention policy at docs/compliance/data-retention.md or contact us for a copy.

8. Your rights

Under the Australian Privacy Principles, you have the right to:

• Access (APP 12) — request access to personal information we hold about you
• Correction (APP 13) — request correction of information that is inaccurate, out of date, incomplete, or misleading
• Anonymity (APP 2) — where practicable, interact with us anonymously or under a pseudonym (note: not possible for clinical records)

To exercise these rights, contact us using the details in Section 10. We will respond within 30 days.

For patients: Requests relating to your clinical records should be directed to your treating anaesthetist in the first instance.

9. Data breaches

If we become aware of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme (Part IIIC, Privacy Act 1988).

We will notify affected subscribing practices within 24 hours of becoming aware of a confirmed breach involving their patient data.

10. Contact us

For privacy enquiries, access requests, or complaints, contact our Privacy Officer:

If you are not satisfied with our response, you may lodge a complaint with the OAIC:

11. Changes to this policy

We may update this policy from time to time. Material changes will be notified to subscribing practitioners by email at least 30 days before taking effect. The current version is always available at anaestra.com.au/privacy.